FLSGP-R-95-001
C3
FLORIDA SEA GRANT COLLEGE PROGRAM
E/TP-1
A HACCP Program for Penaeid Shrimp
Page218
A HACCP PROGRAM FOR RAW, CULTURED PENAEID SHRIMP
LOAN COPY ONLY
CIRCULATINGCOPY
W. Steven Otwell ¹ and George J. Flick, Jr. 2
1Food Science and Human Nutrition Department, University of Florida, Gainesville, FL 32611 USA
2 Department of Food Science and Technology, VPI and State University, Blacksburg, VA 2406I USA
ABSTRACT
Shrimp continues to represent one of the safest forms of
muscle protein consumed in the world, yet as for all seafoods,
they will be subject to additional regulatory scrutiny through
increasing use of Hazard Analysis and Critical Control Point
(HACCP) programs for product safety. This example of a HACCP
plan for cultured penaeid shrimp is recommended for consideration by producers, processors and importers of raw, fresh and
frozen, shell-on or peeled shrimp tails. For this product form the
primary critical control point is product receiving with a distinct
critical limit for sulfite residuals. This plan is complimented by
reference to appropriate Total Quality Assurance (TQA) programs to guide production practices and a sanitation control
plan for in plant operations. Completion and implementation of
these plans remains a company responsibility with additional
and new record keeping requirements. The anticipated benefits
are compliance for international commerce, less regulatory scrutiny per firm, consumer/buyer confidence and market access.
INTRODUCTION
Shrimp continues to represent one of the safest forms of
muscle protein consumed in the world. Amongst seafoods, it is
possibly the least problematic product in terms of reported illnesses per volume consumed. This situation was recently evidenced in the United States by the National Fisheries Institute
NFI 1989). National Academy of Sciences (NAS 1991). and FDA’s
Fish and Fishery Products Hazard and Control Guide (FDA 1994draft) and HACCP proposal (FR 1994). Collectively, these publications list a variety of potential health hazards that could be
associated with shrimp consumption. but actual reported illnesses
or outbreaks are rare and usually involve mishandling or crosscontamination in retail/food service settings or home. No doubt,
shrimp are comparatively much safer than fish or chicken which
have been estimated to cause 1 illness per 5,000,000 or 25,000
servings, respectively (Otwell 1989).
Despite this safety record, shrimp and all other seafoods will
continue to be subject to increasing scrutiny for product safety
and quality. The motivating factors include more health conscious consumers and increasing competition for international
commerce. This situation involves all aquatic food products, be
they harvested, cultured or fabricated. The current, dominant
regulatory response is hazard analysis and critical control point
surveillance. HACCP regulatory programs exist in Canada, they
are being formulated and demanded about the European Union,
and they were recently proposed as a mandatory program in the
United States (FR 1994).
This brief HACCP plan for raw aquacultured shrimp illustrates some of the basic HACCP concepts and offers one initial
approach for commercial and regulatory experience. Typical
shrimp aquaculture and related raw product processing operations should not have difficulty with the implementation of basic HACCP programs. Initial confusion can be resolved with
proper training to understand the basic principles and program
expectations. Likewise, the perceived nuisance for extra monitoring and record keeping can progress to better plant management and employee commitments.
HACCP CONCEPT
HACCP is not a new concept. As a preventative maintenance program it has been used by various technical operations
and food processing facilities for well over 30 years (NAS 1985,
FR 1994). It simply involves a pre-planning procedure to fully
outline an operation, noting potential hazards that could occur
and identifying control points to prevent, minimize or correct
hazards. Record keeping is an essential part of the program to
monitor for practice. consequences and trends. In most instances
shrimp processing firms have intuitively practiced HACCP activity, but they have lacked the specified monitoring and record
keeping procedures.
As introduced, HACCP was a management style adopted
by individual company decisions. but the U.S. FDA’s recent proposal (FR 1994) would make HACCP a mandatory requirement
for all seafood processors and domestic importers. FDA’s mandatory HACCP proposal is based on the basic principles best
outlined by the National Advisory Committee on Microbiological Criteria for Foods ( NACMCF 1992). This selected committee
recommended use of 7 steps in planning and monitoring the
HACCP program (Table 1). FDA’s initial HACCP proposal deleted steps for corrective action and verification. Interpretation
and use of these HACCP principles can differ by firm, regulatory
agency and country. For example in the United States. FDA’s
proposed program mandates the “shalls” for HACCP plans with
steps for seafood safety, while recommending the “shoulds” for
the various attributes of product quality and product integrity
(economic fraud). The “shalls” are the enforceable part of FDA's
HACCP program. In contrast, another federal agency. the Na-
C.L. Browdy and J.S. Hopkins. editors. Swimming through troubled water, Proceedings of the special session on shrimp farming. Aquaculture ‘95. World
Aquaculture Society. Baton Rouge. Louisiana. USA.
Otwell and Flick
Table 1. Seven basic principles or steps for a HACCP program
(NACMCF, 1992).
Steps
Procedure
Conduct a hazard analysis to determine potential safety
problems associated with the seafood processing operations from production through final product commerce.
Page 219
Table 2. A condensed version of FDA’s proposed HACCP obligations for U.S. based importers of fishery products (FR,1994)
1.
Importers shall have their own HACCP plans for products
while in their control.
2.
Importers shall have HACCP plans on file for each of its
foreign processors.
3.
Importers shall take actions to ensure the products imported
were produced under the HACCP plan on file and subject to
FDA specified sanitation controls. Such steps may include,
but would not be limited to:
Identify critical control points (CCP) in processing
Establish critical limits (CL) for each CCP.
Establish monitoring requirements for each CCP and
CL.
Obtain foreign processors HACCP records
Obtain ‘certification’ from foreign government authorities that the processor compiles with HACCP
C. Regularly inspect the processors operations for
HACCP compliance.
d. Periodic end product testing.
e. Other measures . . .
Establish corrective actions to be taken when monitoring indicates a deviation from the CL.
Establish effective recordkeeping procedures.
Establish a HACCP verification procedure.
tional Marine Fisheries Service in the U.S. Department of Commerce has established a voluntary, fee-for-services HACCP program that addresses both product safety and quality through all 7
basic steps (FR 1985). Both federal programs are good, but they
should be distinguished. FDA is the primary food safety regulatory authority in the U.S. governing all domestic seafood production, processing and importing. They are complimented by
the voluntary NMFS program which is often used by buyers and
sellers to assure quality and safety in purchase. Further explanation of the respective programs is beyond the intent of this text,
but additional information can be obtained from their headquarters;
U.S. FDA-Office
of Seafoods
200 C Street, SW
Washington, DC 20204
National Marine
Fisheries Service
1335 East West Highway
Silver Spring Metro
Center Bldg., Rm 6140
Silver Spring, MD 20910
In brief, aquacultured shrimp imported and/or processed in
the U.S. will be subject to FDA’s proposed mandatory HACCP
requirements. The final rule is expected in summer 1995, and
compliance will follow through 1996 and 1997. Many firms are
not waiting for a final rule. They reason that experience with
HACCP implementation before the expected compliance dates
could offer marketing advantages. Canada and some European
nations are currently requesting evidence for HACCP practice.
As proposed (FR 1994),U.S. importers would be required to have
4.
Importers receive product from a country with an active
memorandum of understanding (MCU) with FDA per
HACCP.
5.
Importers encourage foreign processors to obtain HACCP
training per FDA specifications.
on file the HACCP plans of each of its foreign processors. Proof
for a valid and equivalent HACCP program could involve a variety of methods, including active participation by the respective
foreign authorities (Table 2). Obviously, the time for HACCP
planning has arrived.
HACCP PLAN
Raw penaeid shrimp, as the primary product form for most
cultured shrimp, is used to illustrate a possible HACCP plan following the basic principles in Table 1. The final product form is
frozen, shell-on shrimp with or without heads. This example
only features product safety in compliance with FDA’s mandatory proposal (FR 1994). The plan will be an actual written document that identifies the firm, products of concern, potential hazards, critical control points, critical limits, monitoring procedures
and associated records. Establishing a plan is a company responsibility. FDA does not plan any pre-approval process. Compliance will rely on company performance evidenced through
routine regulatory activity.
The HACCP document along with progressive records would
represent a firm’s HACCP program. The document should list
the firm’s address (location), telecommunications and key per-
Page 220
sonnel (i.e. owners, plant managers, HACCP coordinator, etc.).
HACCP plans and records will require signatures denoting maintenance by the responsible persons identified in the plan. Likewise, each firm should employ at least one individual who has
successfully completed a prescribed course of HACCP instruction. The educational requirements are being addressed by a
recently formed ‘Seafood HACCP Alliance for Education and
Training’ initially funded by the National Sea Grant College Program (1994). This project involves a partnership of FDA, state
agencies, industry and academic expertise. The specific training requirements are expected to be released with FDA’s final
HACCP rule.
A HACCP Program for Penaeid Shrimp
RAW FRESH/FROZEN CULTURED PENAEID SHRIMP
Production / Processing Flow - Diagram
-RECEIVING
POND HARVEST (TQA)
- PROCESSING
optional weigh
I
Transport (Chilled)
I
Off-Loading (*)
I
De-Icing / Washing
1
Step 1. Hazard Analysis
The FDA does not require an illustrated flow-diagram of the
production and processing operations. This approach is helpful
for identifying potential hazards and critical control points. The
process in Figure 1 yields fresh or frozen raw shrimp with shellon. Options include heading. Mindful of potential health hazards, the firm must list possible and reasonable problems that
could occur in this process. FDA has drafted a Hazards and
Controls Guide to help identify potential problems (FDA 1994draft). For raw aquacultured shrimp this guide lists three potential hazards: 1) chemical contamination; i.e. pesticides, industrial
chemicals, etc., 2) food and color additives, and 3) aquaculture
drugs.
Many other concerns such as temperature abuse in processing, microbial contamination, decomposition and filth should also
be considered as hazards. The first draft of FDA’s Hazards and
Controls Guide (FDA 1994) does not list Salmonella, Vibrio or
Listeria as hazards on raw cultured shrimp for critical control
point monitoring in raw cultured shrimp processing. These potential bacterial pathogens would still be subject to regulatory
scrutiny through import sampling. FDA reasons these pathogens
are destroyed by cooking and can be prevented by proper sanitation control procedures. For this reason FDA’s initial mandatory
HACCP proposal requires a written sanitary control plan with
appropriate monitoring. This mandate is basically record keeping for traditional GMP’s (“good manufacturing practices”, CFR
1986). The primary safety hazards are addressed by critical control procedures. The distinction between critical control points
and sanitary control plans is more obvious in daily practice and
proposed record keeping procedures.
Step 2. Critical Control Points
Table 3 is the part of a typical HACCP plan that identifies the
critical control points (step 2) and progresses through the setting of critical limits to listing of the records to be kept. By reviewing the flow-diagram it should be obvious that prevention
of the three potential product safety hazards can all be controlled
optional weigh
I
Culling |
I
optional heading
Grading
I
I
I
optional heading
I
Weigh / Pack / Label
- STORAGE
Refrigerated
Storage (*)
I
Frozen
Storage (*)
- SHIPPING
Transport
Transport
(TQA)-subject to total quality assurance plan
(*) - critical control point.
Figure 1. Flow - diagram for processing raw cultured penaeid shrimp to
produce fresh and frozen shell-on product.
or monitored at harvest and receiving. It is best to prevent or
eliminate these problems before they enter processing. If these
problems are discovered during or after processing, then corrective actions and possible rejection can be more difficult, less
likely and more costly. Critical control points are located at any
point where hazards need to be either prevented, eliminated or
reduced to acceptable levels. All significant hazards identified in
step 1 must be addressed by an effective critical control point.
Identifying and locating these points requires an understanding
of basic food safety and the processing operations. For this
reason, training is a mandatory part of FDA’s proposal.
Step 3. Critical Limits
In many instances, the critical limits or permissible levels
for certain processing conditions, various chemical residues and
microbial concerns have been established by previous regula-
Otwell and Flick
Page 22 1
Table 3. Raw cultured Penaeid Shrimp HACCP Plan: Steps 2 through 6.
Safety
Hazards
Critical
Control Points
1. Chemical
Critical
Limits
Monitoring
Corrective
Action
Record
Product
receiving
from pond
TQA
Specific analysis
as necessary if
deviation from TQA
Reject product with
contamination or
unapproved chemicals
TQA & any
analytical
work, NUOCA
Product
receiving
from pond
Preservative:
bisulfite residual,
100 ppm edible
portion
Residual screening,
periodic and as needed,
3 steps:
a. Sulfite test strips
b. Malachite green test
c. M-W verification (AOAC
process) outside lab
Reject product
over 100 ppm
sulfite residual on
edible portion
Progressive test
results per pond
harvest
3. Aquaculture
Drugs
Product
receiving
from ponds
TQA
Specific analysis as
necessary if deviation
from TQA
Reject product
improperly treated
or containing illegal
drug residuals
TQA and
analytical results,
NUOCA
4. Temperature
Abuse
Storage
- Refrigerator
- Freezer
below
40°F (4.4°C)
below
0°F (-18°C)
Continuous Time Temperature Charts
(optional periodic
monitoring)
Examine for
acceptable product
and reduce product
temperature
Time Temperature chart
or Periodic
Records. Periodic
Calibrations
Contamination
2. Food
Additives
TQA
NUOCA
- Total Quality Assurance program for culture production
- Notice of Unusual Occurrence and Corrective Actions
tions (FDA 1994-draft), but other hazards may require special
consideration. Without previous approvals, established use or
designated action levels. processors should consider zero critical limits for certain pesticides and drugs. For example there is
a zero tolerance for chloramphenicol in aquacultured shrimp.
With the tendency for introduction of new pesticides and antibiotics through water and feed, shrimp processors should monitor
on the side of caution. Additional information on legal drugs
and pesticides for aquaculture use can be obtained through the
FDA Center for Veterinary Medicine, Office of New Drug Evaluations in Rockville, Maryland and the FDA Office of Seafoods
in Washington. DC. Their roles and activities are explained in a
useful publication produced by the USDA (1992). Critical limits
must be set as the guidelines for critical control point compliance. Effectiveness and acceptance of a HACCP plan rest with
current and appropriate critical limits.
a total quality assurance (TQA) plan for the entire production
procedure (Table 4a). The TQA specifies how and when all approved chemicals are used, throughout all stages of pond production. Any deviations should be justified and recorded. Unintentional deviations may require water and product analysis by
an appropriate lab to assure compliance with the critical limits as
a declaration of the companies commitment to product safety
before processing. Good TQA examples can be obtained from
the Catfish Farmers of America (1993) and the US Trout Farmers Association (1994). Their programs feature standards for farm
management practices, water quality. broodstocks, feeds and feeding, and animal health, including use of medication. All TQA
participants agree to maintain records for medication and chemical applications. Their agreements are a voluntary pledge that
can be substantiated with a ‘verifier’ with appropriate professional experience. These records can supplement a processors’
HACCP records.
Step 4. Monitoring
The HACCP plan should list the actual procedures to be
used in monitoring the critical control points to assure the shrimp
stay within the stated critical limits. Routine pesticide and drug
analysis is not practical for most shrimp processing firms. As a
preventative measure some aquaculture operations have drafted
Routine procedures for field and process plant application
do exist for monitoring of sulfite residuals on the edible portion
of shrimp. Sodium bisulfite and metabisulfite have been used to
control ‘blackspot’ or melanosis on penaeid shrimp since the
early 1950’s. These reducing agents retard the natural
polyphenoloxidase enzymes that create the black surface pig-
A HACCP Program for Penaeid Shrimp
Page 222
Table 4a. Total Quality Assurance (TQA) record for cultured shrimp production. This example is based on the recommended
Total Quality Assurance programs by the Catfish Farmers of America (1992) and US Trout Farmers Association (1994).
Water Quality
Date and Time
for Test
Pond
Water Analysis and
Product Analysis
Reason for Analysis
and Reason
Sampling Plan
Results
Medication and Chemical Application Record
Date and
Time for
chemical use
Pond
Diagnosis
(reason for
treatment)
Treatment
(drug or
chemical used)
Rate / dose
ments. Likewise, bisulfites help bleach the pigments thereby
imparting a brighter, clean appearance. These actions result in
sulfite residuals, both free and bound, on the shell and muscle
tissue. Previous studies have concluded the original sanctioned
sulfite procedure for shrimp (1.25% bisulfite dip for 1 minute;
Camber et al. 1957) would leave less than 100 ppm (parts per
million) on the edible portion of penaeid shrimp (Finne and Miget
1985). This work substantiated FDA’s regulatory action level of
100 ppm (FR 1985 and 1988). Other countries have established
sulfite residual action levels ranging from 0 to 60 ppm. Since the
original sanctioned procedures were for on-vessel use, commercial practice with sulfiting agents has changed and weaker treatments can offer effective controls for cultured shrimp. The need
for action levels still remains due to adverse sulfite-induced allergic-type reactions that can occur most commonly with certain
asthmatic consumers. Although there are limited investigations
or reported illnesses implicating sulfites as the causative agent
on shrimp, the action levels are easily and often enforced.
A three phase test procedure can be used for monitoring
sulfite residuals on shrimp (Table -4b). Phase one is a sulfite test
paper check that only indicates distinct problems or suspect product. Commercially available sulfite test strips cannot accurately
measure parts per million (ppm) on edible shrimp meat, but they
can reflect a general level of concern based on the intensity of
color changes when touched to the meat surface. The second
phase is a malachite-green procedure (DeVries 1985) that can be
adjusted to measure acceptance or rejection about a set sulfite
residual level. This procedure only requires a blender, balance
and pre-mixed dye. Preliminary trials are required to determine
the ratio of blended meat to dye that responds to a set residual
limit. For an official or FDA recognized analysis, processors
must finally rely on the recognized Monier-Williams procedure
Applicator
Date of
last dose
Time of
last dose
Withdrawal period
expiration
(date and time)
(AOAC 1990). This procedure requires equipment and expertise
beyond the practical capability of most operations.
Step 5. Corrective Action
FDA’s proposed HACCP program only recommends firms
to pre-consider possible corrective actions in the event that a
critical limit is exceeded. Pre-documented corrective action procedures are not required, but recommended. Actions can range
from product rejection to various methods of adjustment or reconditioning to assure the product complies with the critical limits. All corrective actions should be recorded with subsequent
monitoring to assure the product is in compliance. Specified
corrective actions are a probable addition for FDA’s final rule.
Step 6. Records
Each critical control point and related monitoring procedure
will be accompanied by an actual record of activity (Tables 4ad). The records may be continuous, i.e., temperature charts for
refrigeration, or periodic, i.e., daily lot sampling. The records are
the most essential part of the HACCP program. They represent
the firm’s commitment to product safety, and they can be used to
judge company performance. If the HACCP document identifies
a certain record, then this form should be available for regulatory
review. As proposed by FDA, a company’s HACCP performance
will be linked with a regulatory ranking for further surveillance.
An incentive for accurate and thorough records that reflect on
the actual operations and product will be less regulatory scrutiny for the processing firm and/or importer.
If possible all existing records should be considered for direct or modified use as HACCP records so as to minimize the
Otwell and Flick
Page 223
Table 4b. Typical recording form for critical control point monitoring for sulfite residuals on raw cultured penaeid shrimp.
Raw Cultured Penaeid Shrimp HACCP plan
Records
1. Receiving
Date
Pond*
Sample
Sulfite Residuals
Test Strip
Malachite Green
Action
M-W
Key to Positive Results:
Test Strip Ratings:
1. <lOO ppm (pink), 2. Suspect, 3. >I00 ppm (brick red)
Malachite Green Score:
1. <l00 ppm, 2. Suspect, 3. >I00 ppm
M - W (official procedure, Monier-Williams, AOAC, 1990): Average ppm for three tests /outside lab. (list name)
*Sampling.- Random accumulative sample, as product is received at the processing plant. Sample initial, med and latter portion of off-loading. Total
sample size 20 - 30 lbs. Subsamples for each test procedure: test strip - 6 samples; MG - 6 samples; M - W.3 samples. Samples taken per pond
harvest with or without sulfite treatments.
amount of record keeping. For example, an invoice or record of
incoming product could also identify checks for sulfite residuals.
Combining records can be useful, but it should not compromise
confidential production information. FDA’s proposed regulatory concerns rest primarily with product safety. All HACCP
records must be maintained or filed for one to two years if the
products are fresh or frozen, respectively.
Step 7. Verification
FDA's proposed mandatory HACCP proposal does not require a verification plan. Verification is considered a company
responsibility to assure their HACCP plan is effective. Verification can involve periodic end-product testing, in-plant and outside audits, and annual plant reviews. Verifications can also include calibrations or checks on monitoring methods or devices.
Any change or addition to the processing operations would require modification of the HACCP plan and verification. FDA’s
final HACCP rule will most likely include some verification requirement. The ultimate verification is an FDA HACCP inspection.
SANITATION CONTROL PLAN
In addition to the basic HACCP plan with critical control
points for product safety, FDA has proposed that every processing firm should have a written sanitation control plan that includes adequate record keeping for performance. This requirement is one of the more controversial and debated parts of FDA’s
HACCP proposal. The requirement basically addresses all “good
manufacturing practices” and emphasizes certain points for
particular attention. Concerns range from cleanliness and sanitation of operations, equipment, surfaces, and clothing, etc. to
personnel hygiene, pest control, time-temperature controls, etc.
The expectations are reasonable, but tedious record keeping requirements have been questioned.
Assuming record keeping is required or generally accepted
by a firm, these sanitation record keeping procedures could be
segregated by plant operations managers and by time (Table 4cd). Most sanitation procedures require ‘continuous monitoring’
which could be recorded by the actual ‘begin and end’ working
time of an assigned employee (Table 4c). For the more routine
periodic procedures, i.e. daily, weekly or monthly activities, may
require actual logs to designate completion of procedures (Table
4d).
SUMMARY
Despite the safety record for consumption of cultured penaeid
shrimp, as for all seafoods, further regulatory scrutiny is expected
in the form of HACCP programs. The safety associated with raw
cultured shrimp is evidenced by the simplicity of the HACCP
plan for raw cultured shrimp. Following FDA’s proposed HACCP
mandate, firms can anticipate needs for TQA plans and monitoring for sulfite residuals and storage temperatures. In the United
States the burden of proof for HACCP compliance is proposed to
rest with the domestic importer. Processors should initiate HACCP
planning to gain experience in advance of the final FDA rule
expected in mid- 1995.
A HACCP Program for Penaeid Shrimp
Page 224
Table 4c. Partial example for a daily sanitation record for ‘ continuous items’ to be controlled in a shrimp processing plant sanitary
control plan. The record is structured by plant personnel responsible for items that require continuous attention. Deviations and
corrections in procedures are recorded asNUOCA’s (notice of unusual occurrences and corrective actions) and compliance is denoted
by the appropriate daily signature.
Any Shrimp Co., Inc.
Daily Sanitation Record
Continuous Items (From pre-operation review thru end of work day)
NUOCA
- General housekeeping to avoid clutter that hampers plant operations and sanitation.
- Plant layout and general condition helps prevent product contamination and assures sanitation.
- No condensation on pipes, ceilings or other surfaces that could result in product contamination.
- Equipment, facilities and processing utensils in good operating condition and able to be sanitized.
- All wet and dry waste materials segregated and removed from the plant into proper disposal.
- Brushes, trash cans and clothes used to clean and sanitize are color coded to distinguish.
- All product containers stored in clean, dry area free of personnel and product traffic, and
protected from pests.
- All chemicals for equipment use, pest management, cleaning and sanitizing must be stored segregated
and separate from the processing area.
- Convenient hand wash facilities. clean and properly equipped.
- Water supply approved.
- Ice supply clean and protected from contaminants due to floor traffic or equipment contact.
- No worker with illness, open or infected wound will be allowed to come in contact with product or
plant operations.
- No worker will be allowed into the processing area without previous training for food handling and
sanitation.
- No personnel will be allowed in the processing area without clean garments and hair covering.
- Control all personnel traffic. Only authorized personnel in processing plant operation area.
Date
HACCP Record Manager
Date
Plant Manager
Otwell and Flick
Page 225
Table 4d. Partial example for a daily sanitation record for ‘periodic’ items to be controlled in a shrimp processing plant’s sanitary
control plan. The recorded is structured for the personnel responsible for certain items that require periodic attention at specified time.
Deviations and corrections in procedures are recorded as NUOCA’s (notice of unusual occurrence and corrective action) and daily
compliance is denoted by the appropriate signature
Any Shrimp Co., Inc.
Daily Sanitation Record
“Periodic Items”(D=Daily Time; W=Weekly Time & Day)
Time & NUOCA
- Conduct Pre-operation review for general plant condition and sanitation. including workers.
Listed time marks beginning for “continuous” records.
D*=
- Clean and sanitize shucking area and surfaces that contact product; tables, drains, floor, walls,
utensils and equipment; At least once daily and/or before each break and at the end of operations.
D=
D=
- Clean and sanitize the cooler / refrigeration storage. Daily for dry clean and weekly for full
cleaning and sanitization.
D=
w=
- Clean and sanitize washroom areas and facilities.
D=
- Inspect and clean as necessary all waste disposal areas and completely clean and wash weekly.
All waste containers should be clean and sanitize daily.
D=
w=
- Inspect plant premises for clutter and general filth that may attract pests; clean and remove
excess weeds, vegetation, waste, etc.
w=
- Inspect all areas for presence of insects and/ or rodent and implement rodent control program.
w=
- Inspect lighting and ventilation for proper operation or possible product contamination.
w=
- Inspect all chemical storage for segregation from processing area and possible leakage or spills.
D=
- OTHER:
* D = time of day
W = time of week
Date
HACCP Record Manager
Processors should note that HACCP regulations are not intended to replace existing regulations. In reality. the proposed
program is in addition to current regulations. Imported shrimp
processed under a HACCP plan are still subject to product sampling and possible rejection. particularity for decomposition, filth,
chemical contaminants, microbial content, improper labeling and
various economic frauds. The advantage of an effective, recognized HACCP plan is proposed to be less regulatory scrutiny.
HACCP is an honor system with the reward of product/firm confidence. This concept is new, evolving and a significant challenge for international seafood commerce.
Date
Plant Manager
LITERATURE CITED
A.O.A.C. 1990. Official methods of analysis, Association of
Official Analytical Chemists, 15th Edition, AOAC, Inc., Arlington, Viginia, USA.
Camber, C.I., M.H. Vance, and J.E. Alexander. 1957. The use of
sodium bisulfite for the control of blackspot in shrimp. State
of Florida Board of Conservation Technical Series No. 20.
Page 226
A HACCP Program for Penaeid Shrimp
Catfish Farmers of America. 1993. Catfish Quality Assurance.
Indianola, Mississippi, USA.
Otwell, W.S. 1989. Regulatory status of aquacultured products p
Food Technology 43(11)103-105.
Code of Federal Regulations (CFR) 1986. Current good manufacturing practice in manufacturing, packing or holding human
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Agriculture, Beltsville, Maryland, USA.
DeVries, J. 1985. Determination of the presence of sulfite (>I00
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Mimmesota, USA
Finne, G. and R. Miget. 1985. Use of sulfiting agents in shrimp
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products. INFOFISH Marketing Digest, No. 4/85:39-40.
Federal Register (FR). 1985. Notice to shippers, distributors,
packers and importers of shrimp containing sulfites. US
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Food and Drug Administration (FDA). 1994. Fish and fishery
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National Academy Press, Washington, DC, USA.
National Advisory Committee on Microbiological Criteria for
Foods (NACMCF). 1992. Hazard analysis and critical control point system. International Journal of Food Microbiology 16: l-23.
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